-24- expert’s conclusions as to the value of the property as of the contribution date. D. Assessed Value of Subject Property We now address the assessed value of the subject property. The assessed valuation of property is also evidence of the property’s value where, as is the case in Nebraska, the assessed value is defined as the property’s fair market value. See N. Trust Co. v. Commissioner, 87 T.C. 349, 382 (1986); Neb. Rev. Stat. sec. 77-112 (1996 & Supp. 2000). Assessed valuation may be used to corroborate fair market value determined under the three traditional approaches. See N. Trust Co. v. Commissioner, supra. Here, the Antelope County assessor determined that the assessed value of the subject property for 1998 was $70,424. The assessment took into account physical depreciation, economic obsolescence, and functional obsolescence in valuing the property. We place great weight on the assessed value of the subject property because it corroborates the actual sale and the valuation of respondent’s expert as indicators of the fair market value of the subject property. This unrelated third party valuation, close to the values in the prior sale and determined by respondent’s expert, reinforces our view that the purchase price of the property is persuasive evidence of its true fair market value.13 13Petitioners contend that the value the Antelope County assessor determined is somehow biased and the assessor was simply (continued...)Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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